Electricity Market Review. Discussion Paper

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1 Steering Committee 25 July 2014

2 ii Disclaimer State of Western Australia The information, representations and statements contained in this publication have been prepared for the and are provided for discussion and general information purposes only. Views expressed in this publication are not necessarily the views of the Western Australian Government or Minister for Energy and are not government policy. The State of Western Australia, the Minister for Energy, the members of the Project Office and Steering Committee, and their respective officers, employees and agents: (a) make no representation or warranty as to the accuracy, reliability, completeness or currency of the information, representations or statements in this publication (including, but not limited to, information which has been provided by third parties); and (b) shall not be liable, in negligence or otherwise, to any person for any loss, liability or damage arising out of any act or failure to act by any person in using or relying on any information, representation or statement contained in this publication.

3 Executive Summary iii Regulated retail electricity prices in Western Australia have increased substantially between and In addition, taxpayer funding of the industry by way of operating subsidies is now at record levels. Annual operating subsidies (including Horizon Power) are forecast to grow to $600 million within the year. While this is partly because of increases in costs associated with the generation and network elements of the energy supply chain, these costs alone do not adequately explain the tariff increases that have occurred. This is aimed at eliciting feedback from industry participants about the structure and performance of the Wholesale Electricity Market (the WEM), the underlying reasons for cost increases and the options available to address these problems. The questions posed in the paper reflect the concerns of the Steering Committee. The most basic question to which we seek an answer can be framed as follows: is the electricity industry in the south west of Western Australia working efficiently in the best interests of customers? In order to answer this wide ranging question we have posed several specific questions in chapter 3 of the paper. These are: Why is the cost of supplying electricity to retail customers so high that it requires a significant taxpayer subsidy to keep tariffs at levels comparable to those in other Australian states? Could the current industry structure, that is the number of separate generators and retailers, result in a competitive market under any market mechanism? Why can high volumes of generation capacity be added each year, with the costs passed through to customers, when there is clearly no requirement for it? Are network costs reasonable and does the network access code enable long term efficient entry and exit of plant? What does the current primary fuel situation indicate for the availability and price of fuel for future generation? Is the current trajectory of electricity costs and taxpayer subsidies sustainable? The paper presents comparisons of generation costs with other Australian states which, while taking into account differences in underlying fuel costs and the size and conversion efficiency of power stations, show that the generation costs passed through to retail tariffs in Western Australia are significantly higher than in other states. The recent merger between Verve Energy and Synergy should help achieve cost savings between generation and retailing and we pose the question whether more firms are required in the market carrying out similar but competing activities. We have examined the concentration of both the wholesale and retail electricity market around Synergy and suggest that it will be very difficult to create the conditions for competition at both levels while this one company controls such a high proportion of the market. The savings from the recent merger would be maintained and, we believe, enhanced by the benefits of a competitive market by the structural separation of Synergy into two or more generator/retailers. In considering the substantial quantities of new capacity added to the Western Australian electricity market we have examined the influence of the Reserve Capacity Mechanism (RCM), which is used to assess and then attract and pay for new generation capacity in the South West Interconnected System (SWIS). The RCM is an important part of this Review as it appears to be a major contributor to the high generation costs in the SWIS. The RCM involves the acquisition of capacity by the Independent Market Operator (IMO) annually, two years in advance. In , the market had an average capacity utilisation of just 35 per cent, meaning out of all the capacity that customers pay for on average only one third is being used.

4 iv With regard to the Western Power network, network tariffs covering transmission and distribution amount to about 37 per cent of the residential tariff. This is lower than most network service providers in the National Electricity Market (NEM), even though we might have expected Western Power s costs to be slightly higher than average given Western Australia s widespread network. The Code governing the use of the network and electricity market participants access to the network is different to the set of rules in the NEM in a number of respects. While there is no need for it to be the same if it is operating efficiently, there are concerns that it tends to treat new market participants seeking to connect differently to established participants. This can have the effect of making it easier to keep older and higher cost plant while making it more difficult to connect newer, low cost generation. The outlook for coal and gas supplies in the south west is also considered. The current markets for these fuels indicate that their costs are likely to rise in real terms over the coming years. Such an outlook reinforces the need to stabilise or reduce other electricity generation and retailing costs and make the supply chain as competitive and efficient as possible. In the next four years the average cost of electricity in the SWIS is projected to increase by up to 20 per cent. Short of any significant changes in the cost outlook, or the trajectory of tariff increases relative to that announced by government, the annual subsidy from taxpayers will be over $600 million or more than $2.4 billion in these four years on a business as usual basis. This suggests the current burden on taxpayers from the electricity subsidy paid to Synergy will increase - a major impetus for reform in itself. Increases in tariffs for both domestic and commercial or industrial customers will also continue to erode the state s competitiveness and will constrain economic growth to levels below what could otherwise be achieved. While the next four years is expected to see further increases in subsidies to customers (in the absence of reform) the longer term outlook could be even more challenging. As we have discussed above, there will be upward pressure on coal and gas prices. In addition, there will be potential increases in network costs given asset replacement costs and the expense of servicing a peakier load profile. Should the present industry structure and market mechanism be retained, taxpayers will still be required to fund the majority of new investment (network and generation). Taxpayers currently underwrite 76 per cent of capacity in the market either through direct ownership or bilateral contract commitments. In considering the current industry structure, we identify the dominance of state-owned enterprises and the absence of full retail contestability (FRC) as potentially constraining competition that would drive efficiencies and place downward pressure on costs. Within the high level options discussed in chapters 4 and 5, we identify two alternative paths for industry reform. These alternatives are: progressive evolution of existing mechanisms to help deal with the dominance of state-owned enterprises and the WEM rule change processes; or, a fundamental change to the design of the marketplace. The latter would see the WEM operate in the same way as the NEM. We also consider the continuing relevance of the current capacity plus energy design of the WEM. This was developed amid expectations of continuing growth in electricity demand and a primary objective of reducing risks of insufficient capacity. We identify that this market design has not coped well with a static and declining demand, or the difficulty in forecasting block loads. These circumstances have resulted in customers paying for substantially more capacity than necessary to meet design standards for system security. In light of this, the question is posed whether a fundamental change to the industry structure and market design may be necessary to improve market outcomes and reduce costs. We observe that while the WEM rule change process has addressed some undesirable market outcomes, the rule change process in itself is not well suited to the types of fundamental change that may be required, including the option of the Western Australian market joining the NEM.

7 1 The Introduction Regulated retail electricity prices for residential customers in the SWIS increased by 86 per cent between and Over the same period, underlying electricity costs have increased at a similar rate. Despite the significant tariff increase, it has not been enough to cover the cost of supply and the subsidy paid to Synergy for small retail customers 1 has risen sharply and will continue to do so. Several factors have driven electricity cost increases across Australia. These include increases in network costs, subsidies for renewable energy and the carbon tax. While Western Australia has not escaped these nationwide trends, the Review looks particularly at cost increases that have arisen locally and whether they are an outcome of the industry structure and the market mechanisms existing within the WEM. The WEM was created in 2006 and it is timely to consider how the market has performed and whether it will serve Western Australia well in coming years. There will be further upward pressure on electricity costs in the future and it is important that the Western Australian system of electricity production and delivery is the most efficient and cost effective it can be. 1.2 The Terms of Reference On 6 March 2014, the Minister for Energy launched a broad based review of the structure, design and regulatory regime of the electricity market in the south west. The Minister expressed concern that the electricity market was not functioning as expected and has contributed to higher electricity prices. The focus of the Review is broadly to identify and address deficiencies in the market. The Review has three objectives: Reducing costs of production and supply of electricity and electricity related services, without compromising safe and reliable supply; Reducing government exposure to energy market risks, with a particular focus on having future generation built by the private sector without government investment, underwriting or other financial support; and, Attracting to the electricity market private-sector participants that are of a scale and capitalisation sufficient to facilitate long-term stability and investment. The review is being undertaken in two phases: Phase 1 assess the strengths and weaknesses of the current industry structure, market institutions and regulatory arrangements and examine options for reforms to better achieve the Objectives. Phase 2 detailed design of a set of selected reforms and implementation arrangements. The Terms of Reference are provided in Appendix The membership of the Panel The Steering Committee for Phase 1 of the is: Paul Breslin member of the Stanwell Corporation Board in Queensland, former CEO and Director of ACIL Tasman and former Director-General of the Queensland Department of Minerals and Energy; Nicky Cusworth, Deputy Director General at the Department of State Development; and, 1 Customers consuming less than 50 MWh per annum.

8 8 Dr Ray Challen, Deputy Director General at the Department of Finance Public Utilities Office and Coordinator of Energy 1.4 The Review process The Steering Committee encourages individuals and organisations to contribute towards the process by making a submission to this paper. Submissions are due by 12 September A Market Participant Consultation Group workshop and briefing will be held on 21 August Individuals who have already submitted an expression of interest for this group will be notified of the details via Public Submission Process Submissions can be made: By By mail Project Office Public Utilities Office Department of Finance Locked Bag 11 Cloisters Square WA 6850 Content of Submissions A template for submissions has not been provided, as the nature of is wide ranging and varied and it is anticipated that public submissions will be of most value if interested parties are able to make a submission in their area of expertise. As a guide, submissions should aim to answer the relevant questions posed within each section of the. They should focus on market outcomes under proposed reform options one and two, and what industry structures and market mechanisms will result in a more efficient and effective market. Publication of submissions Submissions will be available for public review at unless you request otherwise. Please indicate clearly on the front of your submission if you wish all or part of it to be treated as confidential. Contact information, other than your name and organisation (where applicable) will not be published. Requests may be made under the Freedom of Information Act 1992 (WA) for any submissions marked confidential to be made available. Requests made in this manner will be determined in accordance with the provisions under that Act. 1.6 Project Office Contact Details Simon Middleton Project Director Ph: M:

9 2 History 9 Western Australia s electricity industry has experienced many fundamental changes since the mid-1970s. In July 1975, the functions of the State Energy Commission and the Fuel and Power Commission were combined to form a new organisation: the State Energy Commission of Western Australia, or SECWA. SECWA became responsible for electricity production and gas and electricity distribution, retailing, industry regulation and informing the state government on matters relating to energy policy. In the late 1980s the federal government embarked on a micro-economic reform policy agenda and the electricity industry, where significant improvements in efficiency and productivity were believed possible, became one of the most important focuses of this program. The (then) Commonwealth Industry Commission reviewed the sector and, in May 1991, released its final report recommending, inter alia, separating ownership of key functions in each industry and progressively selling much of the publicly owned generation and distribution assets. 2 In 1992, the state government commissioned the Energy Board of Review (EBR, chaired by Sir Roderick Carnegie) to investigate the structure of the state s electricity and gas industries. 3 The EBR delivered its final report in April 1993, recommending competition in non-monopoly parts of the gas and electricity industries. Implementation of these recommendations involved the creation of two new entities in January 1995 Western Power and Alinta Gas. 4 Many of the benefits foreseen by the EBR were achieved by the two new entities, including gas prices reducing considerably, new gas intensive projects attracted to the state 5 and a decrease in real electricity prices. In August 2001, the state government established the Electricity Reform Taskforce (ERTF) with the objective of creating a more competitive electricity industry, although the ERTF terms of reference did not extend to consideration of privatisation of any part of (the then) Western Power. 6 The ERTF was asked to deliver recommendations on a number of matters including the extent of disaggregation of Western Power, FRC and a new market design in the form of the state s WEM. The ERTF recommended the continuation of the bilateral contracts market that existed in the SWIS at that time with further evolution of the market design to be considered at a future time. 7 The ERTF also recommended the creation of a residual trading market through which energy balancing and limited trading around uncontracted energy requirements would occur. It was hoped that this would facilitate the entry of new generators and retailers. At this time, Western Power expressed concerns that rapid demand growth, hot summers and a peaky load, combined with the isolation from the rest of the NEM might result in supply shortages. 8 This concern, as well as some features of the new market, such as a price cap and bidding constraints in the short-term market, led the ERTF to include a capacity acquisition mechanism. This involved the IMO forecasting capacity requirements several years ahead and ensuring that its projected capacity was acquired and passing the cost of this on to customers. 2 The Industry Commission, Energy Generation and Distribution in Australia, 1991, Preface. 3 Energy Board of Review, WA The Energy Challenge for the 21 st Century Western Australia 1993, pp See Electricity Corporations Act 1994 (WA) (as originally passed); Gas Corporations Act 1994 (as originally passed). 5 For example, the Worsley Alumina Refinery cogeneration project, TIWEST cogeneration project and the BP Refinery cogeneration project. 6 Speech by Hon Eric S Ripper MLA Deputy Premier; Treasurer; Minister for Energy Thursday, 13 September Available at [accessed 5 June 2014]. 7 Electricity Reform Task Force, A Framework for the Future, p17. 8 Western Power, Business Case for the Construction of the Cockburn Combined Cycle Gas Turbine (CCGT), 2001.

10 10 While the market rules required the state-owned generator (later known as Verve Energy and now Synergy) to provide standby generation and all ancillary services, the initial market design envisaged this as a transitional arrangement until sufficient alternatives were available. 9 The ERTF s recommendations were endorsed by government in November 2002 and included the vertical disaggregation of Western Power Corporation into four separate entities generation (Verve Energy), networks (Western Power), retail (Synergy) and regional power (Horizon Power), and the establishment of a wholesale electricity market. The WEM was established in 2006 and steps were taken to mitigate the perceived market power of Verve Energy and Synergy. These included: The Vesting Contract (2006) which imposed a wholesale price cap on a significant proportion of Verve Energy s plant portfolio at disaggregation. The Vesting Contract was meant to ensure the financial viability of both Verve Energy and Synergy in the move to a competitive electricity market. It was also meant to support market development by providing appropriate incentives to both entities to progressively negotiate electricity supply agreements on commercial terms outside of the Vesting Contract arrangements; 10 A 3,000 megawatt (MW) cap on Verve Energy s generation portfolio, restricting Verve Energy s ability to invest in new generation plant, thereby encouraging independent generators to increase their market share over time. Renewable energy projects were not included in the cap; 11 and, Restrictions on Synergy generating electricity and Verve Energy retailing electricity at least until 2013 (subsequently extended to 2016). 12 The design of the Vesting Contract has had significant implications for the development of competition in both the wholesale and retail markets. At the time of disaggregation, most of the wholesale energy sales between Verve Energy and Synergy occurred under vesting contract arrangements. However, it was expected that the influence of the Vesting Contract would reduce quickly as: The expiry of inherited retail contracts and increasing tariff sales created an immediate need for new bilateral contracts in the wholesale market; The Vesting Contract volume automatically declined as contestable tariff customers moved to contract-based offerings; and, Synergy displaced Vesting Contract volume through competitive tenders, to the extent permitted (and required) by the mandatory displacement timetable (the Displacement Mechanism). 13 The Vesting Contract was structured on net-back principles, with Synergy retaining a predetermined margin from its total revenues and the residual revenues netted or passed back to Verve Energy. This design had significant adverse consequences for the financial sustainability of Verve Energy. Synergy had a protected retail margin, while Verve Energy was effectively exposed to the full implications of a lack of cost reflectivity in retail tariffs. The net-back revenues that eventually flowed to Verve Energy were in many cases insufficient to cover its wholesale cost of supply and did not allow the business to extract a consistent return on investment. 9 Electricity Reform Task Force, A Framework for the Future, 2002 p Office of Energy, CBSC Recommendation Paper: Vesting and Initial Supply Contracts, 17 June 2005, p3. 11 Ministerial Direction under the Electricity Corporations Act 2005 to the Electricity Generation Corporation. Available at: (accessed 27 June 2014). 12 Sections 38(1) and 47(1) of the Electricity Corporations Act Office of Energy, CBSC Recommendation Paper: Vesting and Initial Supply Contracts, 17 June 2005, p5.

11 Under this arrangement Synergy had operated profitability since its inception but Verve Energy was subject to substantial losses. 14 These concerns, among others, were the stimulus for the Verve Energy Review in The Verve Energy Review considered the reasons for the business historical poor financial performance, its financial outlook and options for addressing a number of observed problems with the operation of the wholesale electricity market. In , Verve Energy achieved a net profit after tax of $97.5 million. The improved financial position was a result of an increase in retail tariffs in April 2009 (following a 10-year freeze) and the introduction of government subsidy payments to Synergy (the Tariff Adjustment Payment or TAP). 11 The Verve Energy Review recommended that tariffs and charges be further increased to efficient levels as soon as possible with the aim of removing barriers to retail competition. It also recommended that the Vesting Contract s Displacement Mechanism be altered as soon as possible, largely to end prescribed displacement based on Synergy s price protected market. The Verve Energy Review also recommended that, with the advent of FRC, the Vesting Contract should expire and both Synergy and Verve Energy should be allowed to compete for market share in the generation and retail segments. The original Vesting Contract was terminated in October 2010 and replaced with a new contract. Among other items, it removed the previous net-back contract structure and incorporated a much simpler pricing structure. Further, some of the energy balancing flexibility Synergy had under the original contract was removed so that the new arrangements moved closer to a contract structure more typical of private sector wholesale contracts. Although the Replacement Vesting Contract addressed problems arising from the net-back arrangements and Displacement Schedule, it was nevertheless an administratively-generated solution to a market problem, and it created other market distortions of its own. In particular, the structure of the minimum energy nomination requirements (take-or-pay) levels in the Replacement Vesting Contract had the unintended consequence of Synergy buying more energy from Verve Energy than was required to service its load. Synergy sold the excess in the Short Term Energy Market (STEM). By mid 2012, the Replacement Vesting Contract had produced the bizarre situation in which Synergy was, on average, a net seller of energy in the STEM and Verve Energy was a net buyer. In April 2013, the government announced the merger of Synergy and Verve Energy with the objective of harvesting savings from the combined entity without adversely affecting reliability, security of supply or private investment in the sector. The merger took effect on 1 January 2014, with the merged entity retaining the name Synergy. One important outcome of the merger was that existing contracts between Synergy and Verve Energy including the Replacement Vesting Contract fell away, removing the take-or-pay requirements under those contracts. The merged entity is now able to optimise how it utilises its generation portfolio and wholesale procurement contracts to meet its load requirements. A further consequence of these contracts falling away is that new, more flexible, contracting instruments have been put in place (such as the standard products regime). This should facilitate greater market efficiency and transparency with greater access afforded to other market participants to enhance competitive outcomes. The merger has also made possible further opportunities for contract restructuring and flexibility and removed some of the impediments to future restructuring of Synergy, potentially arising from this, or other, reform processes. In this regard, the merger of Synergy and Verve Energy can be seen as an evolutionary step for future reforms. 14 These losses were estimated to be in the vicinity of $250 million of pre-tax losses ($285 in 2014 dollars), out of a total of $454 million ($518 in 2014 dollars), over the three financial years; See Verve Energy Review 2009, Deloitte Oakley Greenwood p. 5. Available at: (accessed 27 June 2014).

12 12 Through the vertical integration of its generation and retail businesses, the state is now better positioned to economically apportion the combined portfolio of generating assets, wholesale procurement contracts and retail contracts between any future horizontally-separated entities. The merger has also allowed the merged entity to focus on cost reduction, a critical underpinning of future reform. However, as the merger combined the largest retailer in the market with the largest generator, there were understandable concerns about its size and market share. As a result, regulations were made to impose ring-fencing, business segregation, transfer pricing and non-discrimination obligations on the merged Synergy.

13 3 Is the market delivering? 13 Electricity markets were developed as a way of enabling competition in electricity generation where competition had previously been seen as impossible. Electricity cannot be stored economically and demand and supply must be matched at all parts of the system in real time. It had generally been accepted that a centrally planned and managed system was necessary to do this but market mechanisms were developed in the 1980s which promised significant improvements in the way electricity was generated and sold. It was shown at the time that such markets could achieve much higher levels of economic efficiency than the vertically integrated monopolies they replaced. 15 Economic efficiency here refers to both short term (static) and long term (dynamic) efficiency. Short-term efficiency is maximised when at any time the system is using the lowest cost combination of plant to meet system demand and the lowest cost reserve is available to the system in the case of outages or changes in demand. Electricity markets provide this when they operate a transparent real time auction, accepting generation offers from lowest to highest price until demand is met. Most buyers and sellers in electricity markets also seek the certainty and risk management benefits of electricity contracts across the market. But a transparent real time market is essential to allow competition, transparent price setting and the basis for contract prices. Long-term efficiency relates to the way in which the market develops over time. This includes providing timely signals for investment to enter with the size and type of plant that the market requires and for the exit of older or higher cost plant that cannot compete with new and more efficient technology. Previously, the vertically integrated and centrally planned systems increased their capacity as they saw fit and passed on these costs to customers via regulated tariffs. The risk of the investment was passed on to customers rather than borne by the investor. These approaches to assessing market efficiency provide a reasonable guideline for assessing the performance of the WEM. Questions that are pertinent include: Do we have a transparent market that results in the economic (least cost) dispatch of plant to meet demand at any time? Is the market price a good guide for longer term contract prices? Does the market encourage appropriate entry and exit of plant? Who bears the risk of new entry? These questions are considered further in this chapter, often through comparisons between outcomes in the NEM and the WEM and sometimes by looking at the operation of similar market mechanisms to the WEM, such as the Pennsylvania New Jersey Maryland Interconnection (PJM) in the northern United States. The contrasts do not necessarily mean that the comparison market is better performing than the WEM; they are simply a means of considering how an alternative market mechanism might achieve outcomes similar to those desired from the WEM. In looking at the performance of the WEM we have specifically considered two features: the industry structure and the market mechanism. Industry structure refers to the number and size of the individual generators in the wholesale market and the number of retailers in the retail market. An industry structure where no single generator has the ability to set prices in the wholesale market would provide competitive outcomes under most wholesale market mechanisms. A structure characterised by one or two generators and retailers having the ability to set wholesale prices and restricted competition in the retail market would usually not provide competitive outcomes under any market mechanism. Market mechanism refers to the mechanism by which generator bids (sometimes called offers) are processed and ranked. Contracts are sometimes netted out of the process (the net pool) or contracts are kept separate from the pool and all generation comes through the pool and is priced in each period (a gross pool). Net pools usually include a price cap on net pool prices and therefore require a capacity procurement mechanism to ensure adequate supplies. 15 Joskow and Schmalensee, Markets for Power, MIT Press, 1983.

14 c/kwh 14 This chapter raises a number of important questions in relation to the performance of the WEM and, after exploring them further below, seeks stakeholder feedback. These questions include: Why is the cost of supplying electricity to retail customers so high that it requires a significant taxpayer-funded subsidy to keep tariffs at levels comparable to other Australian states? Could the current industry structure result in a competitive market under any market mechanism? Why can high volumes of generation capacity be added each year, with the costs passed through to customers, when there is often no requirement for it? Are network costs reasonable and does the network access code enable long term efficient entry and exit of plant? What does the current primary fuel situation indicate for the availability and price of fuel for future generation? Is the current trajectory of electricity costs and government subsidies sustainable? 3.1 The cost of retail electricity in the SWIS, why so high? The SWIS supplies approximately 1.1 million customers and has approximately 6,000 MW 16 of installed generation and Demand Side Management (DSM) capacity. It has over 6,000 km of transmission lines, 95,000 km of distribution lines and it operates in an area of some 225,000 square kilometres. Figure 1 shows a comparison of the components of retail electricity costs in the SWIS compared to each of the main distribution areas in Australia. 17 The data reveals that SWIS transmission and distribution costs are lower than most of the distribution areas shown, which is contrary to expectations as the SWIS is a longer and less dense network than most (other than SAPN and Essential). Figure 1: Retail cost stack (including the Tariff Equalisation Contribution (TEC) in the case of Synergy), TEC Excess energy Energy Network Green Retail Source: Sapere Note 1: Excess energy is an estimate of the impact of excess capacity costs allocated to the A1 tariff class plus 10 per cent of allocated carbon costs. 16 IMO Capacity Credits assigned since Market Commencement Available at: (accessed 27 June 2014). 17 The Synergy cost stack is compared with the cost stack associated with minimum retail tariffs in each jurisdiction. Analysis of typical retail tariffs in NEM jurisdictions showed that there was material retail residual associated with these tariffs, so it is considered that comparison with minimum tariffs provides a better indication of efficient costs.

15 c/kwh 15 Note 2: Carbon costs are included in the above graph, but embedded in energy prices as they are not transparent in all jurisdictions. Figure 2: Wholesale electricity cost comparison for Excess energy Energy Note 1: Excess energy is an estimate of the impact of excess capacity costs allocated to the A1 tariff class plus 10 per cent of allocated carbon costs. Note 2: Carbon costs are included in the above graph, but embedded in energy prices as they are not transparent in all jurisdictions The retail and wholesale cost stacks shown in Figures 1 and 2 reflect that while Synergy s network costs are low relative to its peers, its cost of wholesale energy is significantly greater than most other regions in Australia. Specifically, the portfolio generation cost (energy and capacity inclusive of carbon) attributed to A1 class customers in the SWIS is approximately $180 per MWh, 18 whereas a typical portfolio generation cost in most other Australian jurisdictions is in the range of $60 - $80 per MWh. The exception is South Australia where the typical portfolio generation cost is higher than the average, being over $100 per MWh. 19 South Australia currently relies more heavily on gas fired generation and wind power, and imports electricity from other states. In Western Australia a part of the large difference in generation costs arises from factors such as coal costs in Western Australia being higher than that of Victoria, NSW and Queensland. In addition, Western Australia uses a somewhat higher proportion of gas for generation than most other states. However, coal costs and additional use of gas do not explain such a significant difference in costs. Some specific reasons for higher generation costs in the WEM appear to be: Capacity costs, which are not charged in any other Australian jurisdiction, are high reflecting the costs of excess capacity being allocated to retailers and ultimately customers. Costs embedded in bilateral contracts appear high, possibly reflecting the relatively low transparency around forward prices (including difficulties in marking existing contracts to market) relative to the NEM. Competition among generators is weak. The Western Australian wholesale prices shown in Figure 2 are significantly higher than prices set in the STEM or the balancing market where there is a competitive process and limits on 18 Sapere analysis for the PUO, unpublished. 19 Sapere analysis for the PUO, unpublished.

16 $/MWh 16 Synergy s ability to set prices. Figure 3 shows annual average wholesale prices for the four mainland regions in the NEM and annual average STEM prices. It also shows annual average STEM prices plus capacity costs. 20 While the cost of generation for small residential and business customers is usually higher than average market prices, because of their higher consumption at peak times, the wholesale market should usually provide a reasonable guide to generation costs in retail prices. In the case of residential customers on the A1 (most common) tariff this is clearly not the case. In other words, market prices appear to be irrelevant for a large proportion of customers in the SWIS as contract prices and transfer prices across Synergy appear unrelated to market outcomes. As no other retailer is allowed to compete for this section of the market it is not possible for another retailer to buy from the STEM or the balancing pool and offer residential customers lower prices as they have done in other parts of the contestable retail market. Figure 3: NEM annual average pool prices and annual average STEM and STEM plus capacity prices Calendar year NSW QLD SA VIC STEM STEM and Capacity Source: AEMO, IMO data and ACIL Allen Within the WEM, there are two markets in which participants are able to trade electricity; the dayahead STEM and the Balancing Market. 21 The latter accounts for the differences between participants net contract positions (following STEM trades) and actual outcomes. 20 With the capacity cost on a megawatt per hour (MWh) basis. 21 Participation in the Balancing Market is mandatory for non-intermittent generation facilities with a capacity exceeding 10 MW.

17 Figure 4: Monthly average proportion of STEM offers traded 6% 5% 4% 3% 2% 1% 17 0% September - 06 March - 08 September - 09 March - 11 September - 12 Source: IMO Figure 4 shows the percentage of STEM offers that become trades averaging around three per cent over the period since market commencement. Figure 5 shows the proportion of generation sold under bilateral contracts. Figure 5: Average percentage of total generation that is bilaterally contracted % 110% 105% 100% 95% 90% 85% 80% September - 06 May - 08 January - 10 September - 11 May - 13 Source: IMO Achieving lower energy prices in the retail market therefore appears to rely on bilateral contract prices and transfer prices from the wholesale business unit to the retail business units of Synergy being set in a more competitive environment. This in turn would appear to require a larger number of competitors in the wholesale market, so that the influence of one large incumbent is reduced. If this happened, the implementation of FRC might then allow competitive prices in a wholesale market to be passed on to customers. The limit on Synergy (and previously Verve Energy) building new plant was intended to reduce their market presence over time as new private sector generation entered to meet the growth in demand. This has not yet occurred sufficiently and, on the basis of current growth rates, it is unlikely to occur for some decades to come. As a consequence it is likely that, without reform, current high generation costs will continue to be charged to non-contestable customers and the current high level of taxpayer-funded subsidy will need to be continued if tariffs are to be kept at reasonable levels. The current industry structure and lack of retail contestability will ensure this. 22 Bilateral figures derived from what participants submit as their interval contracted requirement to supply; total generation is the sum of recorded meter readings. Where the average is over 100 per cent, this represents a situation where contracted submissions are higher than what was actually required.

18 18 Market concentration Customers who use between 50 MWh and 160 MWh per year are contestable but can also choose to be supplied by Synergy on a regulated tariff plan. Those consuming greater than 160 MWh per year are wholly contestable so are in effect the only segment in the market subject to effective competitive market forces. Residential customers using less than 50MWh per year are not contestable and are served by Synergy. FRC has been (or is being) introduced in most NEM jurisdictions and Western Australia has implemented retail contestability for the natural gas supply industry (though Synergy is prevented from competing in the segment of the gas market that consumes less than 180 GJ per year). 23 It would potentially be advantageous to enable Synergy to compete in residential segments of the gas market but similarly allow other retailers to compete in the residential segment of the electricity market. Figure 6 shows that although its share has been decreasing, Synergy retains a major position in the retail electricity market with over 60 per cent of all sales. Figure 6: Retail market share in the SWIS by wholesale energy purchased 100% 90% 80% 70% 60% 50% 40% 30% Contestable Tariff (Non-Synergy Market Share) Contestable Contract (Synergy) Contestable Tariff (Synergy) Franchise market (Synergy) 20% 10% 0% 2006/ / /2013 Source: Synergy Retail market concentration is a reflection of the level of concentration in the wholesale market. While the NEM as a whole is a much larger and more diverse market, the retail market within each state is significantly less concentrated than is currently the case in the SWIS. This higher level of competition is because of the move towards FRC; which has been or is being implemented in all NEM jurisdictions except Tasmania. 23 Public Utilities Office Gas Market Moratorium Department of Finance. Available at (accessed 3 June 2014).

20 20 Figure 7: Generation market share by output, July % 1.04% 3.02% 3.86% 13.30% 9.70% 12.50% 53.25% Synergy Bluewaters NewGen Kwinana Alinta NewGen Neerabup Collgar EDWF Other Source: IMO Synergy is also the major buyer of the output of several power stations listed in Figure 7 such as Bluewaters, NewGen Kwinana, the Emu Downs Wind Farm (EDWF) and Collgar Wind Farm. Achieving full retail contestability Achieving a competitive retail market under FRC would require changes to the way some current subsidies are administered. The first, which is an impost rather than a subsidy, is the TEC. This is levied on all customers in the SWIS and is used to fund a subsidy to Horizon Power to support uniform tariffs across the state. The level of TEC collected from customers in is estimated to be $209 million, 24 however it is expected to decrease to $136 million in the financial year. 25 It is not uncommon for state governments to support uniform tariffs by subsidising distribution costs in regional and remote locations. However, in other jurisdictions the funding of these policies is most commonly achieved through a community service obligation (CSO) payment made from consolidated revenue rather than by a charge on non-regional customers. The second subsidy, the TAP, is paid from consolidated revenue. This effectively reduces the level of all Synergy tariffs that are considered not cost reflective, including the A1 tariff. This subsidy has more than doubled since its introduction, increasing from $167.2 million 26 in 2010 to $495 million in In the TAP represented an average annual subsidy of $427 per franchise customer. 28 This equates to a subsidy of approximately 34 per cent of the cost of electricity for the average residential customer supplied under the A1 tariff. In future years, even under scenarios which assume tariff increases in excess of the Consumer Price Index, the TAP has the potential to increase. According to budget estimates, it will be $472 million in Electricity Industry (Tariff Equalisation Contribution) Notice (No. 1) 2013, published in Government Gazette No.67 on 26 April Electricity Industry (Tariff Equalisation Contribution) Notice (No. 1) 2014, published in Government Gazette No. 49 on 4 April Synergy Annual Report Available at: https://www.synergy.net.au/about_us/annual_report.xhtml (accessed 27 June 2014). 27 Department of Treasury, Budget papers no. 3 (Economic and Fiscal Outlook) table 8.7. Available at: 28 Synergy data provided to PUO, unpublished. 29 Department of Treasury, WA Budget Paper No.3, (Economic and Fiscal Outlook), Appendix 8, p297. Available at: (accessed 27 June 2014).

21 Apart from concerns over its increasing cost to government, the TAP may also act as an impediment to introducing competition to the retail market as it provides an advantage only available to Synergy. There are other ways of administering the TAP. One approach is to give it to individual customers rather than provide it as a lump sum to a retailer. It may also be provided to franchise customers as a subsidy paid through the distribution tariff. 21 There are also a number of other barriers for new retail competitors which need to be addressed to achieve a more competitive retail market. For example, restrictions on metering allow Western Power to provide meter data and infrastructure services. This severely restricts the product offerings of entering retailers unless they (or the customer) fund the installation of an interval meter. Additionally, under the Customer Transfer Code 2004, a retailer may not submit more than 20 requests for customer data per business day, 30 severely limiting the number of customers they can transfer to them and effectively preventing competitors from building a viable customer base. Regulatory requirements for customer protection can also be a barrier to entry, given requirements in Western Australia are different to those of NEM jurisdictions, which have or have committed to adopting the National Energy Customer Framework (NECF). The marginal cost of an established retailer in the NEM acquiring a new customer in Western Australia can be much higher than acquiring one in a NECF jurisdiction due to the additional compliance costs associated with regulatory requirements for customer protection. 31 Discussion questions In developing competitive electricity markets how important is the structural separation of Synergy into several generators and retailers? Should the retail electricity market be opened to FRC and should all retailers also be able to retail gas? 3.2 The capacity mechanism, is it delivering the right capacity at a reasonable cost? When the WEM was formed in 2006 the decision to keep Verve Energy as a single generator had an important influence over the subsequent design of the market. The presence of a single generator controlling (then) over 80 per cent 32 of capacity was a concern for the potential entry of both generators and retailers. It would have constituted too high a risk for most potential new investors in the market. Instead of splitting Verve Energy s generation portfolio to allow a level of competition, even if only between state-owned entities, the market designers opted to include a price cap in the STEM and limits on the prices that Verve Energy could bid. Verve Energy was also constrained by government policy from building new generation to service load growth. This was to allow room for the private sector, whose presence was expected to build as rapid demand provided more opportunities for privately owned generation. It was recognised at the time, however, that price caps on the market would remove one of the most important functions of an electricity market (and any market for that matter); which is to provide price signals for new entrants to invest in the market when new production capacity is needed. Moreover, the price signals provided in electricity markets indicate the type of new 30 Electricity Industry Customer Transfer Code 2004 published in Government Gazette No December 2004, p Available at: (accessed 27 June 2014). Please note that this is the subject of a review of the customer transfer code currently being undertaken by the Public Utilities Office. More information can be found at 31 As discussed in Sapere Research Group, Review of Competition in the Retail Electricity and Natural Gas Markets in New South Wales - Report of Interviews with Energy Retailers, February IMO, Statement of Opportunities South West Interconnected System 2005 p.22. Available at (accessed 27 June 2014).

22 22 capacity needed. In the absence of such signals a centrally planned mechanism is required to ensure that supply continues to meet demand every minute of the year. Effectively, the constraints on bidding levels and a market price cap result in the loss of long term, or dynamic, efficiency and this function is replaced by a centrally planned capacity procurement mechanism. In a market such as the NEM, where new entrant investors make their decisions based on market prices and are free to enter or exit when they believe conditions are right to do so, new entrants bear the financial risk of their decision. In a market with a capacity procurement mechanism the financial consequences of inaccurate forecasts, either high or low, are passed on to the customer. The WEM RCM is an important part of this review as appears to be a major contributor to the high generation costs existing in this market. The RCM involves the acquisition of capacity by the IMO annually, two years in advance. The capacity requirement is set by reference to a system maximum demand forecast that has a 10 per cent probability of being exceeded (i.e. has a likelihood of occurring one in ten forecast years) plus allowances for a reserve, intermittent load and frequency maintenance. The RCM allows retailers to secure the required amount of capacity through bilateral contracts or to purchase it from the IMO, which is required to secure capacity to meet any shortfall in the predetermined requirements two years in advance. In order to meet any shortfall, the IMO sets a maximum price for capacity based around the long run cost of a new gas turbine of appropriate size to the SWIS (the Maximum Reserve Capacity Price or MRCP). 33 In setting the reserve capacity price, the MRCP is discounted by 15 per cent and then further adjusted by the ratio of required capacity to the level of capacity accepted by the IMO. The IMO accepts offers of capacity from all parties who make acceptable offers. The price of capacity paid is then reduced proportionately so that the total amount paid remains at the same level as if only the required amount had been accepted at the MRCP discounted by 15 per cent. Interested parties that have generation facilities or demand side management (DSM) programs that are certified by the IMO are generally assigned Capacity Credits for those facilities. A study of the operation of the capacity market in the WEM provides an indication of why generation costs, and capacity costs in particular, are so high. Figure 8 shows the IMO demand forecasts (10 per cent probability of being exceeded) undertaken in July in consecutive years from 2005 to It also shows the actual demand (dotted line). The 2013 forecast is essentially a simple extrapolation of the 2005 forecast. The intervening year forecasts (2006 to 2012) were all significantly higher, with forecasts largely increasing to 2010 and then lower in each year until returning to the 2005 forecast trend in The methodology is set out in detail in an IMO Market Procedure in accordance with market rule 4.16.

23 Capacity/Demand (MW) Figure 8: WEM historical forecasts compared to actual demand Maximum demand Capacity requirement 10%PoE forecast %PoE forecast %PoE forecast %PoE forecast %PoE forecast %PoE forecast %PoE forecast %PoE forecast %PoE forecast 2005 Capacity Credits Acquired Source: IMO, ACIL Allen One of the problems the IMO faces in forecasting and acquiring new capacity is how to take into account the added demand from new mining loads and other projects using large quantities of electricity: so-called block loads. These loads are often prospective, being highly uncertain when they are included in the RCM forecast. By their nature they inflate the forecast significantly. Figure 9 shows the fluctuations of block load forecasts in successive forecasts. The IMO then acquires capacity to cover block load requirements even if a final decision to proceed on the project has not yet been made. The capacity acquired typically open cycle gas turbine peaking plant and DSM is not suitable for supplying the energy requirements of these large block loads, which typically have a large base load requirement. If the project does proceed it will acquire its own electricity contracts, including capacity, in addition to the capacity acquired in expectation by the IMO. In a market prone to large block loads from resource projects whose prospects fluctuate considerably with resource prices, two-year ahead demand forecasts will be prone to error and over-estimation.

24 Entrant capacity or demand (MW) Peak Demand Contribution (MW) 24 Figure 9: IMO forecasts of block loads / / / / /19 Capacity Year Source: IMO data Figure 10 shows the cumulative entry of new capacity into the WEM for to Apart from wind technologies, which are likely to have been driven by the Renewable Energy Target, more than half of the capacity procured over this period was open cycle turbines using either natural gas or liquids. Cumulative entry over the period was just under 2,500 MW, which is considerable given that the current one-in-10 year maximum demand forecast is a little over 4,000 MW. Figure 10: Cumulative new entrant capacity, demand growth and forecast demand growth 3,000 2,500 2,000 1,500 1, Entrant capacity Forecast peak demand growth Peak demand growth Average demand growth Note: A little over 400 MW of gas steam turbine plant was closed by Synergy (formerly Verve Energy) part at the end of 2008 and the rest in Source: IMO and ACIL Allen analysis.

25 Megawatts 25 The previous chart does not include the volumes of DSM that were also offered into the capacity market in each of the years shown. In around 430 MW of demand side response was accepted by the market operator. This capacity received the same capacity payments per MW as each generator that was certified by the IMO. The volume and type of excess capacity added to the WEM in successive years is an indication that the RCM, as it currently operates, is failing to facilitate efficient new entry. While the load factor on the SWIS is relatively low and some new entrant peaking capacity would be expected, the volume of peaking capacity being paid for by customers is clearly in excess of market requirements. As an example, the average capacity utilisation for the WEM in was just 35 per cent. This means out of all the capacity that customers pay for on average only one third is being used. Figure 11 shows the WEM load duration curve compared to the current capacity, including DSM. Figure 11: Load duration curve compared to installed capacity and DSM, Reciprocating engines - 1% DSM - 8% 4000 Cogen - 4% Coal/oil/gas-fired thermal plant - 6% 3000 Open Cycle GT - 35% Wind - 3% 2000 Combined Cycle GT - 14% Landfill Gas - < 1% Sub-critical coal-fired - 29% 1000 Load MW 0 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% Per cent of year Source: IMO and PUO calculations.

26 26 In attempting to estimate the costs of forecasting errors in determining future capacity requirements we have used the data shown in Figure 8. In that figure the July 2013 forecast follows the July 2005 forecast trend. The intervening annual forecasts lie well above that trend. If the intervening annual forecasts are compared to the trend and capacity requirements adjusted to those forecasts (allowing for the absolute margin applied by the IMO above the 10 per cent probability of exceedance forecast in each year) an estimate can be made of the quantity of capacity credits in each year caused by the combined excess forecast and excess purchases. This is shown in Table 2. It is estimated that this combined effect cost $1.03 billion over the nine year period at an average cost of $114.4 million per annum (in nominal prices) in excess of what was needed to ensure a reliable system. Table 2: Excess capacity (incl. forecast error) costs to Year 10per cent POE trend (MW) Capacity requirement margin over 10per cent POE Forecast (MW) Capacity requirement at Trend (MW) Capacity acquired (MW) Excess capacity (MW) Capacity Price ($/MW) Cost ($m) , ,855 4, , , ,020 4, , , ,266 5, , , ,486 5, , , ,626 5, , , ,806 5,996 1, , , ,919 6,087 1, , , ,043 6, , , ,119 5, , Total 1,029.5 Average , Note: Forecast excess capacity is the excess over the 2005 and per cent POE trend forecast. Absolute reserve, intermittent and frequency keeping margin is the same as that allowed by IMO in each year likely to be a conservative adjustment. Source: IMO and ACIL Allen analysis. It is notoriously difficult to forecast peak electricity demand only one year ahead, but a two year ahead forecast is even more challenging. The weakness of the RCM lies not in the forecasting ability of the IMO, as this is likely to be no better or worse than other forecasting efforts undertaken over the same period, but in the use of a process so prone to error and overestimation to determine such a large proportion of electricity costs. The costs of over-investment are not borne by the investors themselves, as they would be in the NEM and in most commodity markets, but by customers and ultimately by government, which provides a subsidy to shield customers from such costs.

27 Table 3: Components of Maximum Reserve Capacity Price ($ per MW per year) 27 Capacity Year 08/09 09/10 10/11 11/12 12/13 13/14 14/15 15/16 16/17 Power Station Cost $79,110 $107,404 $135,701 $134,901 $149,306 $158,710 $113,971 $104,178 $119,942 Transmission Costs $16,558 $18,017 $20,672 $13,151 $58,493 $51,621 $12,329 $12,164 $16,127 Fixed O&M $23,900 $13,363 $14,392 $13,431 $27,335 $26,649 $33,384 $34,239 $33,238 Fuel Costs $2,907 $3,456 $2,631 $3,151 $2,615 $2,825 $2,239 $4,680 $5,442 Land Costs $0 $0 $0 $293 $769 $818 $1,973 $1,783 $2,064 MRCP (nearest $100) $122,500 $142,200 $173,400 $164,100 $238,500 $240,600 $163,900 $157,000 $176,800 Excess Capacity 6.4% 11.4% 2.2% 5.8% 9.0% 14.6% 13.8% 11.0% n/a Reserve Capacity Price (per year) Source: IMO $97,837 $108,459 $144,235 $131,805 $186,001 $178,477 $122,427 $120,199 n/a Table 3 shows the annual calculation of capacity prices in the WEM each year back to In other capacity markets, where capacity prices are set competitively, capacity prices generally trade well below the cost of new entry of peaking capacity. This in part reflects the effect of competition on prices where excess capacity exists and also the expectation that gas turbines might be expected to recover some returns to capital from sales of energy above their short run marginal cost (SRMC). For example in the PJM, capacity auctions for the years to traded between $US11/MW/year and $US63,600/MW/year. The assessed cost of new entry for a gas turbine in the PJM market was above $US100,000/MW/year for all years over that period. This suggests that participants in the PJM capacity market are able to derive more revenue through the sale of energy. 34 While not a complete like for like comparison, the WEM average capacity price was about four times that of the PJM market. While capacity auctions of the PJM kind can work to reduce capacity costs in competitive markets, they may be difficult to run in markets which are not competitive and where the auction might be dominated by one generator. Discussion Questions Could alternative capacity mechanisms work within the current industry structure? Could the capacity mechanism be carried out one year ahead rather than two years to minimise forecasting error? Are there other ways to provide the market with sufficient reserve at lower cost? 3.3 The network: enabling a competitive and reliable wholesale market? Network costs represent about 37 per cent 35 of the residential tariff s cost stack in the SWIS (including the TEC). The level of network costs in the SWIS residential tariff cost stack falls around the middle of the group when compared to network service providers in the NEM. 36 The efficiency of the network is a significant factor in determining the efficiency of the WEM as a whole. This section considers the influence of several important features of the network access code and the way it is administered and the way the network is regulated. 34 Analysis by ACIL Allen for the PUO, unpublished. 35 TEC inclusive, based on analysis by Sapere for the PUO, unpublished. 36 Analysis by Sapere for the PUO, unpublished.

28 c/kwh 28 Figure 12: Network cost comparison (residential cost stack) TEC Network Source: Sapere analysis Network planning and connection Western Power plans its network to meet the criteria in the Technical Rules. 37 These criteria are in the form of deterministic standards that vary across the network and over time. In 2006, there was sufficient capacity in Western Power s network to generally meet these standards and to provide unconstrained network access to connected generators. However, as the SWIS has grown it is becoming more difficult and expensive to provide unconstrained access. Concerns have also been expressed that the unconstrained access approach could lead to inefficiencies in the way generators are selected to run to meet demand and in the connection of new generation to the network. There is also a concern as to whether unconstrained access could lead to over-investment in transmission in the SWIS. For example, in 2010 the Economic Regulation Authority (ERA) suggested that while an unconstrained network approach facilitates simpler operation of the power system and the wholesale market, it does not serve the Market Objectives for the following reasons: It does not promote the economically efficient supply of electricity because it is likely to cause investment in assets that may have a low utilisation; It creates a barrier to competition, as new entrant generators must pay a proportion of the costs of the next network augmentation; and, It is not clear that it minimises the long term cost of supply, in the sense that the requirement may provide more reliability than customers are willing to pay for through increased electricity prices. 38 However, it does not appear that concerns about over-investment have been borne out in reality. Over the last decade, new generators seeking to connect to the network have generally not been prepared to fund the cost of augmentations for the deep network connections that are needed to maintain unconstrained access. Consequently, Western Power has permitted generators to connect to the network on a constrained basis through the implementation of run-back schemes 39 (25 of which are currently in place in the SWIS 40 ) or through other forms of non-firm connection. 37 Western Power Technical Rules Section 2.5. Available at: (accessed 27 June 2014). 38 Economic Regulation Authority, 2010 Wholesale Electricity Market Report to the Minister for Energy, June 2011, pp Run-back schemes are agreements between generators and Western Power that generators will reduce, or run-back, their output under certain network conditions usually concerning the loading on related transmission lines and network facilities. 40 Based on Frontier Economics analysis through discussions with Western Power.

29 These arrangements are consequently very similar to the way in which generators connect in the NEM and in other markets such as New Zealand. In both cases, generators are permitted to connect on the basis of their own assessment of the extent to which likely future network congestion might affect their ability to either be dispatched in merit order or the price at which they will be dispatched. 29 Existing runback schemes in the SWIS do not affect the dispatch of generators who are not party to those schemes. Generators with constrained access are turned down if an event referred to in their connection agreement occurs, whereas generators with unconstrained access are not turned down under the same circumstances. In these cases the differential treatment of different generators in the dispatch process is not based on generators costs or bid prices but on the provisions of their respective connection agreements. Therefore, generators who connected when network capability was less scarce effectively have dispatch priority over more recently connected generators whose access is subject to runback schemes. This will often not be consistent with economic efficiency because providing certain generators with dispatch priority over others irrespective of their relative operating costs will in general not minimise the resource cost of dispatch. In other words it will lower the static or short term efficiency of the WEM as a whole. Discussion questions Would it be more efficient, and cheaper for new entrants, to move to an access code based on constrained connection for all parties connected, similar to that applying in the NEM? Pricing and funding arrangements A revenue cap form of regulation has been adopted for Western Power which determines the maximum allowable revenue Western Power can earn from network charges over the period of its approved Access Arrangement. The primary incentive under the existing regulatory framework is the opportunity for Western Power to efficiently provide operating services and deliver capital expenditure below the level approved by the ERA as it is able to retain a portion of these savings. In addition, financial rewards and penalties under Western Power s Service Standard Adjustment Mechanism (SSAM) provide an incentive for Western Power to maintain or improve performance where the cost of doing so is less than the reward available under the SSAM. The Code includes two capital investment tests, the Regulatory Test and the New Facilities Investment Test (NFiT). The Regulatory Test is applied prior to Western Power committing to network augmentations over specific cost thresholds. To meet this test, Western Power needs to demonstrate that the proposed network augmentation maximises the net benefit after considering alternative options such as demand side management or distributed generation. All capital expenditure, including augmentations subject to the Regulatory Test, is required to meet the NFiT before it can be added to Western Power s Regulated Asset Base. The NFiT is designed to ensure only efficient capital expenditure is passed through to customers and that expenditure is necessary to either maintain safety and reliability or delivers a net benefit or new revenue which is equal to the expenditure. At each access arrangement review the ERA determines whether Western Power s capital expenditure meets the requirements of the NFiT. Preliminary approval is given in relation to forecast expenditure with a final determination made at the next review when the expenditure has been incurred. Western Power is also able to request a determination in between access arrangement reviews in relation to specific projects. Network businesses are heavily dependent on external funding to undertake capital works programs. With networks typically lasting between 40 to 50 years, debt (or equity) may not be paid down for a significant period of time. In Western Power s case its capital expenditure has significantly increased over recent years, with annual capital expenditure now currently averaging around $1 billion per annum. This significant capital works program has increased Western Power s dependence on debt as a funding source as demonstrated in Figure 13.

30 2007/ / / / / / / / / / /18 Capital investment ($mil) Borrowing balance ($mil) 30 Figure 13: Western Power's net capital investment and total borrowings 1,400 1,200 1, Capital investment Total borrowings 10,000 8,000 6,000 4,000 2,000 0 Source: Western Power annual reports for each year and Budget extracts from WA Department of Finance and Treasury. To provide additional context, over the five year regulatory period of Western Power s third Access Arrangement the ERA approved capital expenditure of approximately $6 billion (in nominal dollars). The ability of a government to fund capital works is influenced by a broad range of factors, including budgetary constraints, the chosen fiscal policy (including the credit rating being targeted) and other whole-of-government priorities (for example, health and education). Consequently, a government may not always be able to afford required funding levels to deliver approved network capital expenditure or levels that the network provider views as necessary. Western Power is currently experiencing such constraints as the state government seeks to improve its fiscal position and prioritises spending. Western Power s approved Weighted Average Cost of Capital (WACC) (5.78 per cent nominal pre-tax) for its third Access Arrangement is significantly less than the WACC of network service providers in the NEM (determined by the Australian Energy Regulator (AER)). This is a contentious area. Some contend that the WACC in NEM jurisdictions is too high and has been a contributing factor to network gold plating and resulting higher network costs. 41 Similarly, some contend that the WACC in the WEM is too low and has challenged the ability of Western Power to make an appropriate rate of return on its investments. A lower WACC has a dual effect of lowering the cost of delivered electricity to customers but may dissuade investment in the network. The low WACC further entrenches the role of government in the electricity supply chain because it is reasonable to conclude that private sector capital would not invest in Western Australia when it can achieve a significantly higher rate of return in other markets. Discussion question Financial Years A higher WACC would encourage network investment but could lead to an increase in network tariffs. Is this is a necessary trade-off to achieve a reliable network? 3.4 Fuel for future electricity generation The outlook for generation fuels is an important part of the. We are concerned with the availability of fuel for future generation and the likely direction of future costs. 41 Productivity Commission Electricity Network Regulatory Frameworks Productivity Commission Inquiry Report Australian Government, 9 April 2013, pp. 66.

31 Gas Supply and Demand 31 Western Australia places a greater reliance on gas as an electricity generation feedstock than any other state. About 12 per cent of electricity generated in the NEM is fuelled by gas 42, as opposed to 42 per cent 43 in the WEM. This is unsurprising given Western Australia s abundant gas reserves, and the fact that the state s main actively mined coal fields near Collie in the south west are declining in quality and are progressively mining thinner seams at greater seam depth. Proven offshore reserves of gas in Western Australia are estimated at more than 155,000 petajoules (PJ) or 140 trillion cubic feet (tcf). 44 In addition, the government estimates that technically recoverable unconventional onshore shale gas resources could be as high as 280 tcf. 45 These are estimated to be the fifth largest resources of shale gas in the world. 46 The Western Australian domestic gas market consumes around 1,000 terajoules (TJ) of gas per day (or about 360 PJ a year). 47 As a comparison, Chevron, and its joint venture partners on the Gorgon project, have agreed to supply 2,000 PJ (or about 1.8 tcf) to the domestic gas market over the project s life. 48 The Western Australian domestic gas market is dominated by a handful of suppliers and buyers: up to 570 TJ/d is supplied by the North-West Shelf Gas Project (NWS) with the Apache Joint Venture from Varanus Island supplying up to 390 TJ/d. 49 Domestic gas consumption represents approximately one third of all gas currently produced in the state. 50 By 2020 increases in LNG exports will halve this with the state consuming only about 10 per cent of all gas produced locally. Increases in LNG production will come from projects such as Gorgon and Wheatstone. Export LNG is more attractive than the domestic market for large gas projects given the size of export contracts and the prices that can be achieved. Current LNG prices are around $14/GJ with a netback price of $8 to $9/GJ compared to domestic prices being achieved of $7 to 11/GJ. 51 Western Australia has significant gas reserves as shown in Table Australian Energy Regulator, State of the Energy Market 2013, p IMO, Electricity Statement of OpportunIties, Geoscience Australia, Australian Gas Resource Assessment 2012, pp Department of Mines and Petroleum, Petroleum in WA, April 2014, p CSIRO, Australia s Shale Gas Resources, August 2012, p IMO, Op Cit. 48 Barrow Island Act 2003 (WA), Schedule 1, clause IMO, Gas Statement of Opportunities, January 2014, p KPMG/RISC, Outlook for Fuels for Generation Draft Issues Paper, May 2014, p.9, APPEA data. 51 Ibid, p.8.

32 32 Table 4: Summary of gas field developments Basin Name Project Supply Status Carnarvon NWS Varanus Devils Creek Macedon Pluto LNG 2P 31 Dec 2013 (PJ) 2013 LNG Production MTPA 2013 Average Domestic Gas Production TJ/d Existing 25, ,076 Perth Red Gully/Gingin Existing Carnarvon Browse Carnarvon Gorgon Wheatstone LNG Ichthys Prelude LNG NWS Gorgon P2 Wheatstone P2 Pluto LNG Scarborough Committed 57, Committed 17, Potential 9, Browse Browse LNG Potential 16, Bonaparte Bonaparte LNG Potential 27, Browse Source: RISC analysis Poseidon Crux Contingent Resource Resource only >7000 Many of the fields discovered in Western Australia s offshore basins have either been larger than 5 tcf, or resource owners have been able to aggregate this level of resources over a few fields. 52 In order to achieve acceptable rates of return from these very large offshore investments they need to achieve production rates of at least 500 to 600 TJ per day, equivalent to a one 4 million tonnes per annum (Mtpa) capacity LNG train. This level of daily production is approximately 50 to 60 per cent of the current Western Australian domestic gas market. These lumpy tranches of gas are not easily absorbed into a fully contracted domestic gas market, unless an existing large domestic gas contract expires or a new large gas customer load is established. But they can be relatively easily accommodated in the export LNG market. The development timetable of both smaller scale deposits suitable for the domestic market and larger scale LNG projects is long and ultimately cannot necessarily be timed to coincide with the expiration of sufficient domestic contracts to underwrite their development. From discovery to first production, field sizes of 1tcf for example could take a minimum of 5 years to develop for the domestic gas market, assuming an available market window of demand, and an LNG project could take a minimum 7 to 10 years. As in other areas of the world, Western Australian gas prices are trending upward, as is shown in Figure 14. The dots on the chart represent recent new contracts signed, which are significantly higher than long-term legacy contracts, and thus higher than the current average Western Australian gas price. 52 Geoscience Australia, Op Cit, p.15.

33 Figure 14: Historical global gas prices 33 US$/GJ Japan cif Avg German import price Union cif * US Henry Hub WA gas ex-dmp Recent WA gas contract Source: BP 2013, Department of Mines and Petroleum 2013, IMO Longer-dated gas prices are also increasing, reflecting that international demand for LNG is pulling domestic prices higher, a factor compounded by rising exploration and development costs. Synergy s cheaper legacy gas contracts, which flow from the contracts negotiated by the government with the NWS in the 1980s to underpin that project, have already begun to expire. Synergy has secured most of the gas needed to replace this contract, signing a deal with the Chevron-operated Gorgon project for 125 TJ per day, for 20 years commencing in However, the ERA estimates that Synergy will pay up to triple its previous price for the new gas, 54 which will place upward pressure on electricity tariffs in future. Major oil and gas producers argue that the recent increase in domestic gas prices is, among other things, a function of rising exploration and funding costs and that those higher prices have had the desired effect of bringing new supplies to market. The gas market outlook presents several implications for electricity generation. Availability There is no shortage of physical gas resources in Western Australia. However, the economics of field development for LNG as compared to the domestic market mean that domestic demand is still unlikely to get priority as new fields get developed and large gas contracts are secured. The size and expected growth of the domestic gas market is usually not large enough to capture a conventional gas field development and any unconventional resources, such as shale gas, are still only in the early stages of exploration and appraisal. 53 Energy Minister Peter Collier, Western Australian Government Media Releases, Wednesday, 30 November ERA, Inquiry into Microeconomic Reform in Western Australia Draft Report, April 2014, p. 294.

34 34 There are no apparent resource availability or quality impediments to the reliable supply of natural gas to the Western Australian gas-fired generation sector. However, the commercial factors described above may result in gas production from large offshore projects being locked in LNG export contracts, lowering availability in the domestic market. Price of gas Recent developments in the domestic gas market give some indication that while there will be upward pressure on prices, they might not necessarily reach netback levels. The domestic gas reservation policy gives producers the choice of selling reserved gas in Western Australia now or later. This, and the commercial imperative to monetise reserves, means they may sell at less than netback prices if: a) they have sufficient reserves to run the LNG trains at full capacity; b) they have domestic gas plant with available capacity; and, c) they can make an acceptable rate of return. A high proportion of current supply has met these conditions, which is why LNG producers have reached agreement at prices significantly below netback in recent years. Even without the effect of the reservation policy it can make sense to sell domestic gas at below netback if the LNG trains are operating at capacity. These factors indicate a gas price for future domestic electricity generation higher than that in the current legacy contract and, while market pressure will be towards netback price levels, a number of factors may mean that lower than netback for domestic gas could be achievable. Discussion question Do you consider that domestic prices will reach netback levels or some level below this? Will there be sufficient gas reserves for future electricity generation needs? How can the transparency and liquidity of the local gas market be improved? How can new domestic gas supplies best be encouraged by downstream markets? Coal supply and demand About half of all electricity generated in the SWIS is fuelled by coal. The demonstrated resources of black and brown coal in Western Australia are 42,900 and 8,300 PJ respectively, while the inferred resources are 80,000 and 5,800 PJ respectively. 55 Western Australia has two coal producers Yancoal and Lanco Resources (which acquired the Griffin coal mine in 2010). Both companies mines are located at Collie in the south west. Total coal sales in Western Australia have averaged about 7 Mtpa over the last five years. In , the quantity of coal sold from Collie increased by 7 per cent to 7.5 Mtpa. The market for coal produced in the state is dominated by the power generation sector coal consumption by coal-fired generators in is forecast to account for over 70 per cent of total sales to Western Australian domestic and export markets. 56 Synergy is the main coal customer in Western Australia. It owns Muja A, B, C, D, Kwinana (multifuel), and Collie coal-fired power stations with over 1800 MW of generation capacity. Over the next 15 years, Synergy s coal consumption is estimated to be between 3.8 and 4.4 Mtpa depending on the utilisation of the existing coal-fired generation fleet. Synergy s coal consumption is expected to decrease by about 0.5 Mtpa following the retirement of Muja A and B plants. 55 KPMG/RISC, Op Cit. 56 Ibid.

35 The other major coal-fired power producer in Western Australia is the 416MW Bluewaters power station commissioned by Griffin Energy in 2009 and now owned by Sumitomo and Kansai Electric. Bluewaters coal consumption is assumed to remain steady at 1.6 Mtpa; hence total coal consumption by the coal-fired generation fleet in the SWIS has been estimated at 5.4 to 6 Mtpa. Outside of the generation sector, major industrial users of coal in Western Australia are: 35 BHP Billiton Worsley Alumina refinery with an estimated coal consumption of 1.2 Mtpa; Cockburn Cement with a requirement of about 0.2 Mtpa; and, Mineral sands companies, Iluka and Tronox, each estimated to be consuming on average about 0.15 Mtpa. In addition, coal is also sold in minor quantities to a number of small customers. Limited tonnage is exported through the port of Kwinana with significant volatility of export sale volumes in recent years from 1.1 Mt in to just 0.1 Mt in In addition, Western Australia has significant estimated coal resources at 6.2 billion tonnes (Bt), comprising 930 Mt of economic demonstrated resources, 1.7 Bt of sub economic demonstrated resources and 3.6 Bt of inferred resources. 58 The locations of these resources are shown in Table 5. Table 5: Coal resources in Western Australia Basin Description EDR (Mt) Total (Mt) ² Southern Perth Northern Perth Canning Collie, Ewington, Muja, Premier, Wilga, Boyup Brook and Vasse coal deposits. Eneabba, Irwin River, Saragon, Jurien and Eradu deposits Fitzroy Trough coal deposits including Duchess- Paradise and Liveringa deposits 930 2, Carnarvon ¹ Includes Talisker deposit 0 0 Eucla Salmon Gums, Scaddan, Balladonia and Zanthus deposits 0 2,776 Total 930 6,219 ¹ Reliable resource estimates not available ² Includes: Economic demonstrated resources, sub-economic demonstrated resources and inferred resources Source: Department of Mines and Petroleum Collie coal is a low ash, low sulphur sub-bituminous coal, with low trace elements. It has a calorific value of about 20 megajoule per kilogram. By definition, sub-bituminous coals carry a relatively high moisture content, which lowers the energy of the product. The coal is well-suited for use in power generation and various industrial processes. Western Australia has sufficient coal reserves in the Collie area of suitable quality to supply existing power generators and other existing domestic customers for over 40 years at the current rates of consumption. In addition, there are significant additional coal resources in the Collie area that may be developed, although the mining methods and the costs of production will require further examination. 57 Fremantle Port Authority, Trade Statistics, June Department of Mines and Petroleum. Resource Data Files N.D Aavailable at: (accessed May, 2014).

36 36 There are no apparent resource availability or major quality impediments to providing a reliable supply of coal to the Western Australian coal-fired generation sector. However, there are some commercial concerns at present. Both of the Collie producers have publicly expressed concerns about the rising cost of their operations, compared with the long-term contract prices they are receiving for their coal. It is well known that the seams being worked are becoming narrower with more overburden to remove. If prices need to increase significantly it may be that other coal resources become competitive or, more likely for power stations in the region of the Collie mine, there is the possibility of coal imports from countries such as Indonesia. This would provide an effective cap for domestic prices at import parity levels. Discussion question Do you consider coal resources sufficient for future needs? Other sectors of the mining industry have recently undertaken significant cost-cutting exercises. Is there similar need in the coal industry for greater efficiencies? 3.5 The future: more of the same? The current high cost of electricity in the WEM is the major reason why Western Australian electricity tariffs are so high. These high costs have resulted in tariff increases for all customers despite the state government subsidising Synergy s operating costs by $495 million in Overall subsidies to the industry as noted before (including Horizon Power) are more than $600 million. The level of tariffs and the required subsidy has the potential to increase in coming years. The current lack of competition in both the wholesale and retail electricity markets, combined with the RCM, mean that there are no competitive pressures to counter cost increases or indeed to lower some of the very high costs recently experienced in the generation sector. In the next four years the average cost of electricity in the SWIS is projected to increase potentially by about 20 per cent. 60 Short of any significant changes in the cost outlook or the expected trajectory of tariff increases relative to that announced by the government, the annual subsidy from the government will be over $600 million 61 totalling over $2.4 billion in these four years on a business as usual case, as shown in Figure 15. This is a major impetus for reform in itself. 59 Department of Treasury, Budget papers no. 3 (Economic and Fiscal Outlook) table 8.7. Available at: 60 Derived from Synergy budgetary submissions for Department of Treasury 2014 budget p. 603.Available at: (accessed 27 June 2014).

37 Figure 15: Subsidy to electricity customers 37 $mil forecast / / / / / /17 Source: 2014 budget, PUO data Increases in tariffs for both domestic and industrial customers will also continue to erode the state s competitiveness and may constrain economic growth to levels below what could otherwise be achieved. While the next four years may see further increases in subsidies to customers, in the absence of reform the longer term outlook could be even more challenging. As we have discussed above, there will be upward pressure on both coal and gas prices and potential increases in network costs given asset replacement needs and the costs of servicing a peaky load profile. Taxpayers currently underwrite 76 per cent 62 of capacity in the market either through direct ownership or bilateral contract commitments. Should the current industry structure and market mechanism remain, taxpayers will be required to fund the majority of new investment (network and generation). Discussion question What industry changes need to be made to reduce subsidies? 62 PUO estimation of Synergy Individual Reserve Capacity Requirement.

38 38 4 Options: Industry structure and regulation 4.1 Introduction This chapter and the next discuss some potential options for reform of the electricity industry in the SWIS which will address the underlying problems identified earlier in this. The reform options being considered have been divided into two broad groupings. The first, considered in this chapter, concerns changes to industry structure and regulation. These are changes that appear necessary to allow competition and more transparent price setting in both the wholesale and retail markets. The second, considered in Chapter 5, concerns two broad options to change market mechanisms. The first option encompasses possible changes to the current WEM RCM and the STEM and balancing pool, whereas the second considers a move to a NEM energy-only market. Figure 16: Reform options; industry structure and regulation 4.2 Encouraging competition in wholesale and retail markets The WEM is a highly concentrated market with Synergy owning around 58 per cent of all installed capacity. Other major participants are Alinta, Griffin, NewGen, Vinalco and the Collgar wind farm. Synergy also holds a monopoly franchise covering all electricity customers with annual consumption of less than 50 MWh. This is around 6 terawatt-hours (TWh) per annum, or around 33 per cent of energy sold in the SWIS. Customers with consumption greater than 50 MWh per annum (around 66 per cent of energy sold in the SWIS) are contestable and are supplied variously by Synergy and other retailer participants. Synergy supplied approximately 10.5 TWh or 65 per cent of the energy sold in the WEM in the financial year Synergy data provided to PUO, unpublished.

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